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1.
You are petitioner states that both she and the responded is Hindu,
major and sui juris.
2. Your petitioner states that she and the respondent were married
together according to Hindu rites and custom and solemnization of
their marriage was held on 31st May of 2019, from the resident of the
property situated at Birati in presence of the parents of the
respondent and some common friends of the parties herein and the
marriages between the parties was love marriage. Thereafter
petitioner started her married life at a matrimonial house with her
husband, mother – in - law and father – in - law with necessary
utensils which was given from the petitioner’s family members after
inception of their marriage. Out of their wedlock there is no issue.
3. That immediate after the marriage the respondent / husband and

his parents started creating huge pressure upon the petitioner and also
the family members of the petitioner to fulfill their illegal demand as
dowry. For the happiness of the petitioner the parents of the
petitioner was bound to fulfill some of the demands of the respondent
and his parents. The parents of the petitioner bought as stridhan
articles - a gold ring amounting of Rs. 14,000/-, a solar panel &
battery, Dish (Sun Dish), L.E.D. Television, Mobile charger
machine, Fan, Lights etc. But after receiving these all they were
again started creating pressure for a cash and amount from the
parents of the petitioner. As such the parents of the petitioner
arranged an amount of Rs. 10,000/- from their well wishers and
given to the respondent and his parents.
4. Petitioner states that after few months of their marriage the

petitioner faced misbehave from the respondent / husband and her in-
laws as at her matrimonial house though petitioner tried to fulfill her
duty at matrimonial home. But despite her efforts, neither her in-
laws nor the opposite party accepted her own, due to that, the
petitioner failed to bring money from her parental home as total
demand by the respondent and his family members for boubhat
ceremony and their needs.
5. Petitioner stage that after few days of marriage, she found that the
respondent came to home in a drunken condition in regular basis, for
which his parents never told anything to him. Sometimes the
responding used to stay outside home as said to the petitioner that he
is going for his official work to outside which were beyond her
knowledge. And whenever the petitioner opposed respondent not to
drink alcohol the in- laws and the respondent himself did not hesitate
to with the petitioner.
6. That the respondent / husband is very suspicious in nature. Even in

many occasion he used to stay and spend nights outside of
matrimonial home of the petitioner and if the petitioner ask where the
respondent used to be then he became so angry and started bitted the
petitioner even in that case her in- laws were totally silent.
7. That the petitioner done all the household work in her matrimonial
house without any complains to please them. But, opposite party and
her in- laws always blamed her without any proper reason, they were
always treated the petition with great negligence and cruelty abused
her in filthy languages in the front of her husband and also the
petitioner’s family members whenever they visited the matrimonial
home of the petitioner. But the respondent always supported his
parents and take co-part with them against the petitioner. The life of
your petitioner at her matrimonial home is disgraceful, painful and
totally under pressure and her status in her matrimonial home is just
like a slave who has no right to freedom of expression, which daily
occasion till the last day residing together with husband and wife at
her matrimonial home, it has further states that if the petitioner
unable to bring money from her father she done all the household
works in her matrimonial home singly just like a made servant.
8. That your petitioner states that a great hope of the petitioner that
one day all the acts done by the opposite party and his family
members will be stopped and on the basis of this hope several times
she tried to convince the respondent to maintain a normal life. But,
the respondent did not try to change himself after petitioner’s several
prayers and always neglected her whenever the petitioner raised an
objection of her husband cruel acts as aforesaid and his family
member’s regular incident then the respondent becomes very violent
and bitted her and as a result of the petitioner faced physical torture.
Be it specially mentioned herein that the petitioner never complaint
any relatives or neighbor even to any police station only to maintain
the status of her matrimonial home in the society but also her all
effort come in vein.
9. Get the petitioner states that the inhuman torture by the respondent
and in- laws was increased day after day, it's became intolerable for
the petitioner, as such petitioner was locked by respondent and in-
laws in her bedroom, due to that she was foodless for a whole day, as
because petitioner unwanted fault in her household work.
10. That on 22.06.2020, before the Amfan disaster the respondent /

husband and in- laws bitted the petitioner and she became senseless
out of her matrimonial home. From that situation with the
intervention by the mother of the petitioner, she discovered the
petitioner lonely from that place but till then neither respondent nor
in- laws of the petitioner recovered her.
11. That after such repeated inhuman physical and mental torture, the
petitioner having no other alternative than to file a written complaint
before the Baranagar Police Station and after knowing the gravity of
that complaint the police authority registered an FIR being No. 424
of 2020 dated on 28.09.2020 U/S- 498A / 506 / 323 / 34, IPC against
respondent and his parents.
12. From that 22.06.2020 the responding did not communicated with
the petitioner and as a result the petitioner had no other alternative
than to take shelter at a parental home.
13. That your petitioner states that she has no source of income for
meet the basic necessity of maintenance herself after deserted by her
husband from aforesaid date, presently the petitioner is residing at
her parental home and the father of the petitioner is bearing all
expenses like food, cloth, medicines, etc. of the petitioner which is
badly pressurized to the financial condition of the petitioner’s father
as because the father of the petitioner is Rickshaw driver and from
his small source of income he also maintains entire family
responsibility after bearing his daughter’s responsibilities that is
hammering the financial structure of the father of the petitioner.
14. Your petitioner states that the entire motive of the respondent
appears to be harass the petitioner and his family members, and to
pressurized the petitioner for achieving wrongful gains. In any event,
the marriage between the petitioner and the respondent has now
irretrievably broken down.
15. In the facts and circumstances aforesaid, the responded has

treated the petitioner with cruelty, both physical and mental, and
especially mental cruelty, and the respondent practiced fraud upon
the petitioner to obtain consent of the petitioner to the marriage with
him and the respondent has deserted the petitioner on and from 22 nd
June, 2020.
16. In the circumstances aforesaid, the petitioner is seeking to have

her marriage with the respondent annulled by a decree of divorce, on
the grounds as stated above U/S 13 of the Hindu Marriage Act, 1955
and there is no impediment or bar under law for the petitioner to
present this application, or to seek the relief’s as the petitioner is
seeking herein.
17. In the circumstances aforesaid particularly escapede from the
tortures of the respondent the petitioner is seeking to have her
marriage with the respondent annulled filing his application for
dissolving the nuptial knot existing between the parties by a decree
of divorce, on the ground of cruelty as stated elaborately herein
above within the meaning of 13 of the Hindu Marriage Act, 1955 and
there is no impediment or bar under law for the petitioner to present
this application, or to see the relief’s as the petitioner is seeking
herein.
18. Get the petition is being presented without any unnecessary or

improper delay on part of the petitioner.
19. That the petitioner has not in any manner condoned the acts
complained of or connvied.
20. That there is no other legal ground as to why the decree of prayed
for should not be granted in favour of the Petitioner.
21. That the no litigation has taken place between the parties to the
Petition earlier.
22. There's no collusion between the parties in so far as making of

this application is concerned. Your petitioner for the states that being
deprived of a normal married life was so coveted by her husband of
your petitioner is suffering mentally agony. In any event, the
marriage between the petitioner and the respondent has now
irretrievably broken down which is beyond repair.
23. The cause of action of the instant suit finally arose on and from
the 22.06.2020, the responded didnot communicated with the
petitioner and permanently deserted the petitioner and the said cause
of action is still continuing between the parties. In as much as the
parties lastly residing together as husband and wife at the above
mentioned residence of the respondent which being within the
jurisdiction of this Learner Court. Thus, this Court has enough power
to receive, try and determined this suit.
24. A fixed Court Fee, as is prescribed under law, is paid on this

application.
your petitioner there for humbly prays:
(a) A decree for divorce is passed annulling the marriage

between the petitioner with the respondent solemnized on
31.05.2019.
(b) Any other alternate relief or relief’s be granted.
(c) Such further or other relief or relief’s
And your petitioner as in duty bound shall every pray.

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3. That immediate after the marriage the respondent / husband and

4. Petitioner states that after few months of their marriage the

6. That the respondent / husband is very suspicious in nature. Even in

10. That on 22.06.2020, before the Amfan disaster the respondent /

15. In the facts and circumstances aforesaid, the responded has

16. In the circumstances aforesaid, the petitioner is seeking to have

18. Get the petition is being presented without any unnecessary or

22. There's no collusion between the parties in so far as making of

24. A fixed Court Fee, as is prescribed under law, is paid on this

(a) A decree for divorce is passed annulling the marriage

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